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Use of Administrative Data Sources for Census 2022 Data Protection Privacy Notice


This Privacy Notice explains why we will use Administrative Data for Scotland’s Census 2022.

Administrative data is data held by local and national government or other public bodies. They use it to support their own day-to-day activities. This notice tells you what personal information we have collected from administrative sources, why we have collected it, who we have collected it from, how we will use it, who we will share it with and how we protect it.

Why are we using Administrative data?

National Records of Scotland (NRS) is responsible for conducting the census in Scotland. Scotland has relied for more than 200 years on the information the census provides. It remains the best way to gather vital information which government, councils, the NHS and a range of users in the public, private and third sectors need. The results support the planning and delivery of a wide range of public services which improve the lives of those living and working in Scotland.

We plan to use administrative data to quality assure census returns and to calculate the size of the Scottish population at national and local levels. NRS has expanded its use of Administrative data because of the lower than expected response rate.  Uses include:

  • Linking between administrative data and census returns for quality assurance, flagging errors or inconsistencies in the census dataset, for example Remove False Persons and Resolve Multiple Records.
  • Using administrative data in our statistical modelling to calculate the total size of the Scottish population. We then adjust our overall population estimates so they reflect the total population of Scotland, including those who didn’t complete a census return.
  • NRS uses a statistical method to add imputed records in the place of households who didn’t complete a census form. We will use administrative data to make this process more accurate but we will not add administrative data to the census dataset directly.

Administrative data will be used for statistical purposes, it will not be used to make decisions about individuals directly. For example it will not be used to contact people who have not filled in a census return.

Administrative Data received by NRS

Any Administrative data received by us will be processed either in NRS IT systems or the National Safe Haven. Data will not be shared with anyone else or made publicly available. None of the Administrative data used are from a publicly accessible source. It will only be used by NRS for the purposes mentioned above.

All data will be processed by NRS within the UK.

The table below shows what Administrative data was received by us and where it came from.

Organisation the data was received from

Data received by NRS

National Records of Scotland – NHSCR

Full name

Date of birth

Date of death


Full address including postcode

Unique identifier

National Records of Scotland – Vital events (births, deaths, marriages and civil partnerships)

Full name

Date of birth


Full address including postcode

Date of registration

Unique identifier

Higher Education Student Authority – Student data

Full name

Last name at age 16

Term time postcode

Home postcode

Date of birth


Domicile location

Course length

Current year of course

Date course finishes

Part time or full time student

Scottish Candidate Number

Unique Identifier

Scottish Government - School Pupil Census

Scottish Candidate Number

Date of birth



Electoral Registration Officers – Electoral Register

Full name

Full address including postcode

Date individual is eligible to vote

Overseas flag

Electoral number

Public Health Scotland – Health activity

Unique ID

Full name

Date of birth


Address including postcode

GP practice postcode

Marital status

Ethnic group

Date of last interaction with health service

Flag for people who have left Scotland


Ministry of Defence – Joint Personnel Administration


Full name

Date of birth


Regular or reserve status

Scottish posting indicator

This information will help us to provide data about the age of Scotland’s population and the population levels across the country.

No automated decision-making or profiling will take place

How we will collect the Administrative data

All Administrative data will be sent electronically to NRS via secure file transfer systems. Data will be processed and stored securely within NRS IT systems and in the case that data is processed in the National Safe Haven, it will be stored securely there too. Data will not leave the UK.

Other personal information we may collect to respond to your query

If you contact us  via email, letter or telephone information will be collected online or over the telephone. We may also ask for some personal information so we can reply to you. This may be your name, email address, phone number. For other types of enquiries, we may ask for further details.

Lawful basis for the processing

The lawful basis for the collection and processing of personal data for the census is the ‘public task’ basis – the exercise of official authority vested in the Registrar General for Scotland as the data controller (Article 6(1)(e) of the UK General Data Protection Regulation (UK GDPR)). The statutory basis for the Registrar General’s public task is provided by the Census Act 1920.

The processing of special category personal data is lawful because the processing is:

  • necessary for scientific or historical research or statistical research purposes (UK GDPR–Article 9(2)(j)) in accordance with safeguards required by Article 89(1) of UK GDPR and Section 19 of the Data Protection Act 2018

Our use of administrative data has been approved by two Public Benefit and Privacy Panels (PBPPs), who reviewed our use of health and Scottish Government data. We would need to re-apply to the relevant PBPP to obtain approval should we want to use the data for a different purpose.

Both the organisations sharing the Administrative data and NRS comply with relevant legislation to ensure the sharing, receiving and processing of the data is legal.

 Retention and disclosure of data

Access to, and use of, this data is time-limited. The administrative data used in Scotland’s Census can be held and used until 31st December 2024 and will then be securely deleted. The data will not be disclosed without lawful authority.

Personal information collected during correspondence/queries will be securely deleted after 5 years. The data will not be disclosed without lawful authority.

 Your legal rights

As the data is being processed for statistical purposes, your rights as a data subject are significantly restricted. If you wish to complain or exercise your data subject rights in accordance with the UK GDPR, the Data Protection Act 2018 or any other legislation then please contact us. If you consider the processing of your data to still be inappropriate or unlawful after receiving our response, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO) by visiting them at or by contacting the ICO by telephone on 0303 123 1113.

 Data controller

The Registrar General for Scotland is the data controller for the information we collect and process. You can contact them via our Data Protection Officer at:

Data Protection Officer
National Records of Scotland
HM General Register House
2 Princes Street
Edinburgh, EH1 3YY

Tel. No. 0131 535 1314

Email: [email protected]

Review and changes to this notice

This Privacy Notice is kept under regular review to reflect any changes to the datasets we intend to use or any other changes.  This Privacy Notice is the second version and was published on 13 December 2022. 



  • Accuracy

Is how close a given set of information (responses, measurements, observations or readings) are to their true value.


  • Census

Scotland’s Census is the official count of every person and household in the country. There has been a census in Scotland every 10 years since 1801, except 1941. The 2021 census in Scotland was moved to 2022 due to the impact of the COVID-19 pandemic. The answers people give to census questions help build up a picture of the population. Government and other service providers rely on census data to make important decisions.


  • Health and Social Care Public Benefit and Privacy Panel (HSC-PBPP)

The Health and Social Care PBPP is a Governance structure of NHSScotland established with delegated authority from NHSScotland Chief Executive Officers and the Registrar General to scrutinise any use of NHSScotland controlled data and NHS Central Register data.

The HSC-PBPP provides robust, transparent, consistent, appropriate and proportionate information governance and scrutiny of data access requests to ensure the Information Governance principles of safe people, safe projects, safe data, safe places are maintained.

For more information see here

  • Imputed records

Imputation is when we need to fill in an answer that is missing or seems out of place with related questions. Imputation involves replacing missing, invalid or inconsistent records. Records that have their value imputed are called imputed records.

  • National Records of Scotland

National Records of Scotland performs the registration and statistical functions for the Registrar General for Scotland, including responsibility for demographic statistics and census, and the archival functions for the Keeper of the Records of Scotland.

  • National Safe Haven

The Scottish National Safe Haven is owned by Public Health Scotland and governed by the eDRIS team who control access and manage all research enquiries.

 The National Safe Haven is a secure environment where data is uploaded and accessed. The National Safe Haven operates at all times in full compliance with data protection legislation. For more information on use of the National Safe Haven see here

  • Remove False Persons

A statistical ‘cleaning’ process, where we find errors in the census dataset and take them out, because they don’t respond to a genuine person in the population.

There are a number of processing issues which occur when receiving Scotland’s Census responses. For example, on paper questionnaires scanners can sometimes pick up dust on a blank question and record it as a valid mark, thereby creating a response. However, these marks do not relate to an actual answer from a genuine individual. Generally, these issues affect a small portion of responses received, as most of them arise from errors in scanning of paper questionnaires — the majority of responses in Scotland’s Census 2022 will be online. Nonetheless, such issues can falsely increase the number of people counted in the Census (often referred to as overcount). For that reason, there is a part of statistical data processing called Remove False Persons (RFP), which looks at the possibility of a non-genuine person being made into a person record.

  • Resolve Multiple records (responses)

A statistical ‘cleaning’ process, which makes corrections for cases where people have submitted multiple census responses. This process groups these multiple responses so we don’t count the same person twice.

There are situations where people submit more than one response to the Census, for any number of reasons. Sometimes, this could be due to a miscommunication (for example, where two members of a household think they have not yet responded, so each submits a response), or a respondent attempts to respond to their Census online, creates a Census record, but is unable to complete it, subsequently submitting a paper response as well. When these types of situations occur, the population is ‘overcounted’. This duplication occurs for both persons and households, and needs to be resolved to ensure that Scotland’s population count is not overestimated. This is done in a process called Resolve Multiple Responses (RMR).

  • Population Estimates

Description of the total population size including demographic characteristics such as age and sex.

 Statistics Public Benefit and Privacy Panel (Statistics-PBPP)

The Statistics Public Benefit and Privacy Panel is a governance structure of the Scottish Government. The panel has a formal mandate to scrutinise the information governance relating to requests for access to: Scottish Government datasets; National Records of Scotland (NRS) census data; Linkage to Scottish Government datasets and NRS census data; Research and other well-defined and bona fide purpose

The panel’s focus on public awareness, concern and benefit demonstrates a commitment to the protection and promotion of privacy as a public good and in the public interest.

For more information see here